Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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Nature of receipts - interest earned on FDs during the year was prior to commencement of business - The Appellate Tribunal referred to a previous decision involving the assessee for assessment years 2013-14 and 2014-15, wherein the ITAT Ahmedabad Bench ruled in favor of treating interest income earned on FDs before the commencement of business as capital receipts. Based on this precedent, the Tribunal upheld the decision to treat the interest income as capital receipts. It dismissed the Department's objection regarding the nexus between borrowed funds and investments, deeming it irrelevant in light of previous assessments.
Nature of receipts - interest earned on FDs during the year was prior to commencement of business - The Appellate Tribunal referred to a previous decision involving the assessee for assessment years 2013-14 and 2014-15, wherein the ITAT Ahmedabad Bench ruled in favor of treating interest income earned on FDs before the commencement of business as capital receipts. Based on this precedent, the Tribunal upheld the decision to treat the interest income as capital receipts. It dismissed the Department's objection regarding the nexus between borrowed funds and investments, deeming it irrelevant in light of previous assessments.
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